8801_ROSCANS_1999

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ILL·HOLMAN
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
December 22, 1999
Mr. Mark Taylor
The Fletcher Group
322 South Main Street
Greenville, S.C. 29601
RE: Authorization To Install Monitoring Wells and
Piezometers At Ecusta Ash Landfill, Permit# 88-01
Dear Mr. Taylor,
The Solid Waste Section has received a Facsimile of the
revised Site Investigation Work Plan for the Ash Landfill
at P.H. Glatfelter Company's Ecusta Division, located in
Pisgah Forest, North Carolina. You are authorized by the
N.C. Solid Waste Section to proceed with the installation
of the monitoring wells and piezometers necessary for
this investigation.
The wells and piezometers need to be designed and
constructed in accordance with the specifications in the
North Carolina Well Construction Standards (15A NCAC 2C
.0108), as illustrated by the Typical Monitoring Well
Schematic diagram attached to this letter. For the
shallow well in the alluvial area, it is important that
the top of the well screen not be too close to the ground
surface, in order to ensure an adequate bentonite seal
and grout/concrete annular space that will seal off
surface water infiltration. (Getting this effective seal
is even more important than bracketing the water table
for a shallow well.)
The new monitoring wells should be thoroughly developed
after construction in order to reduce suspended solids,
flush out the well, and re-establish equilibrium with the
aquifer. For each new well, a complete and accurate Well
Completion Record and Well Schematic Diagram should be
submitted to this office in the Investigation Report,
along with geologic and hydrologic information reported
on boring logs.
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1 646
401 OBERLIN ROAD, SUITE 1 50, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLE0/1 Oo/o POST-CONSUMER PAPER
Mr. Mark Taylor
The Fletcher Group
Ecusta Ash Landfill
Page 2
If you have any questions or comments regarding this conditional
authorization to install the monitoring wells and piezometers
necessary for the Site Investigation Plan at the Ecusta Ash
Landfill, please contact me [phone], extension 258.
Sincerely,
~~ Bobby Lutfy
Hydrogeologist
Solid Waste Section
E-mail address: [e-mail]
cc: Jim Coffey, Solid Waste Section
Jim Patterson, SWS Asheville R.O.
Mike Cody, P.H. Glatfelter Company
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 30, 1999
Mr. David M. Cody
Director, Environmental Affairs
Ecusta Division
P.H. Glatfelter Co.
P.O. Box 200
Pisgah Forest, N.C. 28768-0200
DIVISION OF WASTE MANAGEMENT
ReCEIVEb
N.C. Dept. of EHNA
SEP -2 181
Win~ton-Sa/em
Reg,1onaJ Office
RE: Compliance Status Letter of August 9, 1999, For The
Ecusta Ash Industrial Landfill, Permit No. 88-01
Dear Mr. Cody,
This letter is written in response to your letter of
August 9, 1999, with recommendations for performing
several tasks to gather additional information in order
to demonstrate compliance with the 2L Standards. While
additional hydrogeological information is needed in order
to better understand the ground-water flow regime at the
ash landfill, the demonstration of compliance with 2L was
required by Solid Waste Management Rule . 0503 (2) (d) (ii)
to have been done prior to January 1, 1998.
Any future investigation at this landfill should also
focus attention on the ground-water flow in the vicinity
of monitoring well Q88V5 and Thrash Branch. However,
this work should be done as part of the needed water
quality assessment, rather than part of the already due
2L demonstration. The more immediate need is for Ecusta
to proceed with the 11 transition plan11 , including a plan
for closure, as requested in the June 7, 1999, letter
from James C. Coffey .
The Ecusta Ash Landfill has documented evidence of non-
compliance with the 2L Groundwater Standards at the
11 compliance boundary11 • Although the original permit for
the Ash Landfill is dated July 1979, there have been a
couple of permit amendments since that time. After the
II slide /i ncident II in the autumn of 1989, there was a major
permit amendment in March of 1992 with significant design
changes and the addition of property to the facility
boundaries.
401 OBERLIN ROAD, SUITE 1 SO, RALEIGH, NC 27605
PHONE [phone] FAX 919-71 S-3605
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50o/o RECYCLED/10% POST-CONSUMER PAPER
Mr. David M. Cody
Ecusta Ash Landfill
Page 3
At the time the original permit was issued in July of 1979, the
expected life of the facility was for "eight to ten years of
operation". So the Ash Landfill has already been in operation over
twice as long as was originally planned.
Since monitoring well Q88V5 is located beyond the 2L "compliance
boundary" and has shown consistent levels of Sulfates that exceed
the 2L Groundwater Standards, it is clear that the Ash Landfill is
not in compliance with 2L. Therefore, while additional water
quality information is needed, this will be required as part of on-
going water quality monitoring and assessment, rather than as part
of the 2L compliance demonstration, which was due prior to January
1, 1998. Ecusta will need to proceed with the submission of a
"transition plan", including a plan for closure of the existing
landfill and a plan for future management of waste, as required in
the June 7, 1999, letter from James C. Coffey. Since the 60 days
referenced in the June 7th letter is almost over, the Solid Waste
Section will allow an additional 30 day extension for Ecusta to
prepare and submit the required "transition plan".
If you have any questions about this letter, please contact me at
[phone], extension 258, or Jim Coffey at extension 255.
Sincerely,
Bobby Lutfy
Hydrogeologist
Solid Waste Section
cc: Jim Coffey
Julian Foscue
Bill Sessoms
Jim Patterson
Ecusta a division of P.H. GLATFELTER co.
D.M.CODY
P.O. BOX 200 • PISGAH FOREST, NORTH CAROLlNA 28768-0200
TELEPHONE [phone]
Director, Environmental Affairs
Tel. [phone]
Fax [phone]
Mr. James C. Coffey
Permitting Branch
Solid Waste Section
North Carolina Department of Environment,
Health and Natural Resources
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Subject: Compliance Status of the Ecusta Ash Industrial Landfill, Permit No. 88-01
Transylvania County
Dear Mr. Coffey:
August 9, 1999
In your letter, dated June 7, 1999, you stated that the Departments review of the
information on the industrial ash landfill that Ecusta submitted does not show
compliance with the water standards established under ISA NCAC 138 Section
0503(2)(d)(ii)(A)(ie.2L Standard) groundwater standards.
Upon receipt of your letter, we requested Sevee & Maher Engineers, Inc (SME) to review
the information that was submitted to your office. Review of the available information and
data suggests that the ash landfill will meet the 2L Standard. To show compliance with
the 2L Standard SME has recommended several tasks to gather additional information in
order to prepare an addendum to the current application. The tasks are as follows:
1. Install two nested pairs of piezometers and two single piezometers near the
drainage channel along the West End of the site. The single piezometers will be
used in conjunction with nearby stream elevation to determine groundwater
seepage gradients. The alignment of the piezometers will allow SME to
construct a flow net beneath the landfill.
2. Revise the groundwater sampling procedures at the site to use a low-flow
sampling procedure. In our review we found that sampling procedures used to
obtain data at sample well Q88VS was not representative of the groundwater at
the site. Well Q88VS will be sampled and analyzed using low-flow sampling
procedures.
With your approval of this plan in August 1999 we could deliver a final report to you
showing our compliance with the 2L standard by January 15, 2000
If further information is desired, please call me at [phone].
Sincerely,
'J u
PROPOSED PIE FlGURE 1 ECUST ZOMETER L PISGAH''\ Dl"1SION OF ~ TION PLAN OREST. NORTH TFEL TER CAROUNA
SME
Sevee & Maher . Engineers, Inc.
Low-Flow Sampling Procedure. The low-flow sampling procedure, which uses a flow
rate of 100 milliliters per minute (ml/min), will be used to collect the water quality
samples from the monitoring wells at the site. The low-flow sampling procedure
minimizes both drawdown and disturbance within the well, thereby generating a sample
which is representative of the in situ water chemistry at the well location.
Sampling equipment for all of the monitoring locations will consist of a peristaltic pump
with dedicated low density polyethylene (LDPE) tubing. Equipment used to measure
field parameters will be calibrated prior to sampling.
Dedicated sampling tubing will be placed in the well a minimum of 24 hours prior to
sampling. The bottom of the tubing or pump inlet will be positioned at the middle of the
screened interval, or in the middle of the water column if the water table is in the well
screen. Tubing, pumps, or measuring devices will not be placed below the water surface
within 24 hours of sampling, or during sampling of the well.
Procedure for Wells where Drawdown Stabilizes
1. Low flow rates will be used for purging, 100 to 200 ml/min.
2. Water level measurements must be recorded at 5-minute intervals until
drawdown stabilization has been achieved. The static water level and the
pumping start time must be recorded as the first reading on the second
page of the Monitoring Well Sample Purging Form. All subsequent field
measurements will also be recorded on the Monitoring Well Sample
Purging Form.
3. Until drawdown stabilizes, field parameters (pH, specific conductance,
and turbidity) must be monitored and recorded at IO-minute intervals.
4. Once drawdown stabilization is achieved, and once two successive 10-
minute interval field parameter measurements meet the conditions listed
below, complete stabilization will be verified by three successive
measurements at 3-minute intervals which also meet the conditions listed
below:
pH:
Specific conductance:
Turbidity:
± 0. 1 standard unit
±5%
± 10% above 10 NTU
±1 NTUbelow lONTU
Note: It is possible for the field parameters to stabilize prior to or at the
same time as the drawdown.
5. Once complete stabilization has been achieved and a complete set of field
readings has been measured (temperature, pH, specific conductance,
turbidity and dissolved oxygen), the samples will be collected in
appropriately preserved containers. The sampling personnel will complete
and attach labels to each of the sample containers for the location of
interest. Samples will be obtained directly from the pump discharge line.
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Mr. Bob Gussman
Ecusta Paper
P. 0. Box200
Pisgah Forest, NC 28768
NA
DEHNR
June 13, 1997
RE: Coal Ash Model, Ecusta Paper Industrial Landfill, Translyvania County, Permit No. 88-
01
Dear Mr. Gussman:
In a previous letter dated February 26, 1997, the Solid Waste Section (Section) notified
owners and operators of coal ash monofills that the Section would study the possibility of
developing a simple, generic model to demonstrate compliance with the requirements of Rule
.0503(2)( d)(ii)(A). Although you did not receive that letter the items in the letter were discussed
with you in several phone conversations and in a meeting. The study has been completed and the
conclusion reached that the development of such a model is not possible. This conclusion is
based on the following reasons:
1. Infiltration through coal ash monofills is incompletely understood and dependent on
several factors including the self-cementing properties of the ash (which is dependent on
ash type), operation (geometry, disposal rate, compaction, intermediate cover, vegetation,
mixing of ash types, fracture of shallow self-cementing horizons) and climate.
2. Leachate concentrations of metals to be expected in water leaving the ash pile are not
known very well either. They might depend on the infiltration paths and on ash type.
They probably evolve through the life of the landfill. And they may differ significantly
from concentrations measured in a variety of laboratory studies.
3. Existing data on subsurface characteristics are insufficient for all ash monofills in North
Carolina to allow construction of even simple models.
4. Existing groundwater detection monitoring systems at all of the sites do not provide
enough useful information to calibrate or validate any model.
5. There is no data concerning the sorptive capability of saprolite in the Southeastern U.S.
Consequently the previously required submittal must include a final cap system designed
to ensure compliance with the ground water standards as demonstrated by modelling methods
acceptable to the Section.
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50"/o recycled/ l 0% post-consumer paper
Mr. Gussman
June 13, 1997
Page 2
The previously required submittal from the February 26, 1997 letter included the
following:
A construction and operational plan which limits development of the landfill to the lateral
expansion of the waste "footprint" established as of January 1, 1998. The plan shall be
developed in one-year phases and operated in such a manner that the landfill may be
closed at any time.
The capacity of the landfill design plan shall not exceed five (5) years.
A water quality monitoring plan including additional wells located, sampled, and
analyzed in a way that demonstrates compliance with 2L. Please contact Bobby Lutfy of
the Section concerning monitoring and sampling parameters.
A closure plan including a final cap system.
The submittal of this information and acknowledgement of receipt by the Section prior to
January 1, 1998, will constitute compliance with Rule .0503(2)(d)(ii). However; this does not
constitute final determination by the Section that the design ensures that the ground water
standards established under 15A NCAC 2L will not be exceeded in the uppermost aquifer at the
compliance boundary. It should be noted that a lateral expansion beyond the 1998 footprint or a
new landfill must meet all the permit requirements of Rules .0503-.0505, including a
demonstration that the proposed design meets the requirements of Rule .0503(2)( d)(ii).
This letter serves as notification to the owner/operator that the information
previously described as necessary to complete the final determination of compliance with
Rule .0503(2)(d)(ii) shall be submitted to the Section thirty (30) days prior to January 1,
1998.
If there are any questions regarding this letter, please call Susan Leistiko at (919) 733-
0692 extension 262.
Sincerely,
J v::;/i/;&sor
ermitting Branch
Solid Waste Section
cc: Julian Foscue
Jim Patterson
C:IWRIGHTIPROJECTSIINDUSTRLIECUST_88\COALASH.MOD
.·, .. JAMES 8. HUNT jjf
GOVERNOR -~:-'.f: .. 1~:j~~. /{,'. --\t~tt::~ . -::.. ~--..
.. ::~\·:~{.· : .. :,.,: ,;t~11~'" ,,
Mr. Bob Gussman
P.H. Glatfelter Company
Ecusta Division
P.O. Box 200
Pisgah Forest, NC 28768
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
ASHEVILLE REGIONAL OFFICE
DIVISION OF SOLID WASTE MANAGEMENT
SOLID W AS'.P:;o &EC:J'-IDN Mt;;)Ct:fiV~U
February 10, 1999 N ,t"' D"'~p+ qf r,:3=a!l\,.it1 ~ .. \l..J'" ·v_t.~\ ... ij~~u~ij,L.-.
FEB 15 ~
RE: P.H. Glatfelter Company's 10-Year Solid Waste Plan
Transylvania County, NJF
Dear Bob:
The Solid Waste Section has completed the compliance review of P. H. Glatfelter's
Solid Waste Management Plan. It appears that the plan has addressed all the
requirements of General Statute 130A-309.09D(c). We encourage P. H. Glatfelter to
implement the programs as stated in the plan, and to continually review the plan's
effectiveness in meeting your company's goals and the goals of the state iaw. Your
company should modify the plan if conditions change that impact solid waste
management.
I would like to remind you that General Statute 130A-309.09(D)(c) requires that the
owner and operator of industrial facilities update the solid waste plan at least every three
years. If conditions change at your facility sufficiently to warrant a substantial update of
the plan, it can be done earlier than three years.
Thank you and all the other employees of P. H. Glatfelter Company who participated
in the development and implementation of the plan. If you have any questions concerning
this letter or future planning requirements, please do not hesitate to call me at (828) 251-
6208, extension 209.
Sincerely, tfg,-c~
James E. Patterson
Waste Management Specialist
JEP:sb
cc: Julian Foscue
Phil Prete
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 28801
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/10% POST-CONSUMER PAPER
NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Sol id lolaste Ma11age11:1,t
Solid lolaste Section
SOLID YASTE IWIAGEJEIH FACILITY EVALUATl<JI REPalT
Type of Faci L ity fv-,91., 1-y, ·, \ l,. ,Jt 1'1\ Permit ,__._?-.~-i<~_L"_, ___ Colnty fy,-..y,v c 1 \W>I i?
~ J
Nane of Facility Su, },.<!. 0~ f , , t ](:r.Q\ i-, 1 Location ') ,fl_ 1 ~., q , J , " ( 1 ;.:: I , ,../)..
Date of Last Evaluation l \, -< r (Ii
I. Pe,..it Conditions Followed __ '<_Yes No N/A
A. specific condition(s) Violated. _______________________________ _
\I J.J. ~rational Re<J,1irements Followed ___ Yes ___ 110
15A N.C. Adllin. Code 138 Section __ ,_0_'")""'"'_c._)_S ______ _
A. specific Violation(s) by ruiber and Letter.
Ill. Other Violations of Rule or Law ________________________________ _
IV. Evaluator's cai--.ts ____________________________________ _
V. Contiruation Page Re<JJired? __ Yes _(_110
Evaluation Date :;i. S -r, <;
DEHIIR 3793 (Part I "1ite: Facility
Sol id \laste Section (Review 7/94)
-\)", : G.S. l lOA-294 rcqullx'S that an evaluation program be established for the
ope:rattc;n of sol ia WdSte management facilities on a statewide basis. 'Ihe
S0 id wastP. Manaqe:roont Act and Sol id Waste Management Rules cxxlified at
l i.i CAC 13B 1 i.st rfX{Ui rerrents 'Whidl. must be followed by solid waste
r'1 l :it-i
r iJ: -'>01 · d Wru;b:• Sect ion personne-l f'J'lall cx;ttplete the evaluation fom each
t;r. thE"y cornuct official evaluations. 'Ihe fom shall be signed by
tlie pt' non(s) receiving the n>port.
~rt I 'Whlt.E.: f illity oc.py
w:... fl C'ani:.'.rv Raleigh central office file u:,py
Par. I I r Pink RE'>gi.ooa1 off ioe file copy
a-,: 'th· s fonn n.y he retained in accordance with the Record Retention and
l l'l · .i.t:ion f>Chedule of the Sol id WdSte Section, Solid Wa..c:;te ManagemE'..nt
J • v i ; ion of t.o.e Deparboont of Environrrw.=>nt, Heal th arrl Natural Resources.